David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD) -- summary under Subsection 84(2)

proceeds from the sale of cash-rich company to pension fund for wind-up 5 months later were "otherwise appropriated ... on the winding-up"

Approximately four months after the corporation of which the taxpayers (the "David group") were shareholders sold its principal business assets,...

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